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CONFESSIONS OF A
MONEY LAUNDERER by Kenneth Rijock
MONEY LAUNDERER by Kenneth Rijock
Financial Crime Consultant, for World-Check
Confessions of a Money Launderer - Part 93
6 December 2009
As you may have suspected, from time to time I was engaged to participate in what one might call alternative anti-money laundering matters. Sometimes this meant posing as a money launderer for an American law enforcement agency, and stinging some despicable narcotics trafficker. Other times it meant consulting in a civil matter, like the time I was retained to perform enhanced due diligence on a prominent Russian company that wanted to buy a large portion of a successful US medical device company. (It turned out that the Russian company was a front for ROC money laundering). Still other engagements involved conducting money laundering investigations which appeared to be for a civil client, but were probably for a governmental agency that didn't want to publicly be seen as making enquiries. Perhaps the most satisfying involved the opportunities to conduct what I call the "scared straight" seminar, because the preventive nature of the programme is unique. You may also call it "when bad things happen to good bankers."
Here are the details of the programme:
Now, on to the content. the concept is to present the attendees with blunt, real-time situations that could occur in the bank's future operations, and thereby test their reaction time, coolness under pressure, and problem solving ability. It is definitely the business equivalent of a bucket of cold water being thrown on you.
I will generally summarise some of the fact patterns given to the attendees:
Some these fact patterns are admittedly banking nightmares, but each and every one could occur
tomorrow. we test: quality and correctness of response, ability to meet deadlines, ability to create an effective solution, imagination, and sensitivity to reputation damage. How would you answer these questions?
Perhaps you might want to create your own compliance crisis seminar, for they give the attendees a baptism of fire, and thereby prepare them for the real thing.
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- I was engaged by a former senior US law enforcement official to conduct my seminar for his client, a prominent financial institution located in the Caribbean region.
- We held the seminar at an upscale oceanfront resort located some distance from the capital city; invited were all the senior officers of the bank, including the director of compliance, and the owner. it was an intentionally isolated venue. with separate villas for the attendees, rather than a large hotel, so that there was little or no contact with others.
- The primary object of these programmes is to both test the crisis response time of bank senior management, the effectiveness of the compliance team under pressure, and the interface between management and compliance. The secondary objective was to see if there was any preexisting compliance crisis planning in place.
- What we did is place the bankers and bank owner in a small room; they receive special tasking assignments, and are only given fifteen minutes to confer amongst themselves, and come up with a plan of attack, on an emergency basis, and without any outside assistance. They cannot call up their assistants, lawyers or advisers.
Now, on to the content. the concept is to present the attendees with blunt, real-time situations that could occur in the bank's future operations, and thereby test their reaction time, coolness under pressure, and problem solving ability. It is definitely the business equivalent of a bucket of cold water being thrown on you.
I will generally summarise some of the fact patterns given to the attendees:
- A senior vice president of the bank is arrested in the United States, or a country located in the European Union, and charged with money laundering. QUESTION: What steps should the bank take to: (1) protect the bank's reputation, (2) make a preliminary assessment of the bank's liability, if any (3) obtain legal representation for the arrested officer, and (4) deal with the media issues that will inevitably arise.
- A law enforcement agency visits the bank, with the appropriate court order or subpoena, seeking information on a prominent client of the bank. This client, who is a dominant figure in retail sales in several cities, maintains large accounts. QUESTION: what should the bank do under these circumstances?
- Arrests are made of the owners of major several money service business in the capital. Several of these are both present and former clients of the bank, and one is owned by a former bank officer who went to work for a client, and later bought the business, QUESTION: What is the best course of action?
- A relative of a bank employee is designated on OFAC as a significant global narcotics trafficker, and the relationship appears in the local media. QUESTION: What must be done before taking any action with regard to the employee?
- A bank teller is exposed for willfully failing to file currency transactions reports and Suspicious Activity Reports against a specific client who maintain a business which handles a large amont of cash transactions. QUESTION: What do you do?
Some these fact patterns are admittedly banking nightmares, but each and every one could occur
tomorrow. we test: quality and correctness of response, ability to meet deadlines, ability to create an effective solution, imagination, and sensitivity to reputation damage. How would you answer these questions?
Perhaps you might want to create your own compliance crisis seminar, for they give the attendees a baptism of fire, and thereby prepare them for the real thing.
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The facts and opinions stated in this article are those of the author and not those of World-Check. World-Check does not warrant the accuracy of any facts and opinions stated in this article, does not endorse them, and accepts no responsibility for them.
Read more in this exciting series
8 March 2010
8 February 2010
24 January 2010
6 December 2009
27 September 2009
9 August 2009
3 August 2009
30 March 2009
9 March 2009
2 March 2009
22 February 2009
18 February 2009
26 January 2009
18 January 2009
11 January 2009
5 January 2009
29 November 2008
24 November 2008
17 November 2008
8 November 2008
3 November 2008
27 October 2008
20 October 2008
13 October 2008
4 October 2008
28 September 2008
20 September 2008
15 September 2008
15 June 2008
8 June 2008
1 June 2008
26 May 2008
19 May 2008
12 May 2008
4 May 2008
27 April 2008
20 April 2008
13 April 2008
31 March 2008
18 March 2008
4 March 2008
25 February 2008
16 February 2008
10 February 2008
3 February 2008
27 January 2008
20 January 2008
14 January 2008
6 January 2008
16 December 2007
9 December 2007
1 December 2007
25 November 2007
18 November 2007
11 November 2007
3 November 2007
27 October 2007
21 October 2007
14 October 2007
7 October 2007
1 October 2007
23 September 2007
16 September 2007
3 June 2007
27 May 2007
21 May 2007
6 May 2007
30 April 2007
22 April 2007
15 April 2007
8 April 2007
2 April 2007
24 March 2007
19 March 2007
12 March 2007
5 March 2007
25 February 2007
19 February 2007
12 February 2007
4 February 2007
28 January 2007
22 January 2007
15 January 2007
7 January 2007
2 January 2007
16 December 2006
10 December 2006
3 December 2006
27 November 2006
19 November 2006
11 November 2006
5 November 2006
29 October 2006
22 October 2006
16 October 2006
9 October 2006
2 October 2006
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